Besides being a firm specializing in providing investment advisory services, CreativeOne Securities, LLC (f/k/a Client One Securities LLC) (“C1S”) is also a broker-dealer, Member FINRA/SIPC, which began its business in November 2010. The firm provides financial planning, consulting and investment management services to a wide variety of clients. C1S is wholly-owned by Creative One Marketing Corporation, an insurance marketing firm. C1S does not control any other firm. The advisory services of C1S are described in detail below. C1S also offers a wrap fee discretionary management service which is described in a separate Form ADV Part 2A "Wrap Fee" Appendix 1 Brochure. Consulting Services Consulting Services provided by C1S vary by the objectives and financial circumstances of each client. The specific services provided are determined at contract signing and described in the Consulting Services Agreement. Services begin by the client’s C1S Representative performing an analysis of the client's existing assets, insurance, taxes, investment objectives, investments and other related matters. After this information-gathering step is completed, C1S's Representative then confers with the client to provide C1S's recommendations. Advice about investments is generally limited to stocks, bonds, mutual funds, exchange- traded funds, variable life and annuity contracts, and government-issued securities and use of other investment managers. Other topics regarding, for example, insurance, taxes, estate planning, and other matters are addressed in the scope requested by the client. For clients who have a large or highly-diversified securities portfolio or who need extensive financial, estate, tax or insurance advice, C1S may prepare written recommendations which assist the clients in arriving at an investment and insurance mix designed to achieve their investment objectives. The scope of the report is determined in advance between the client and C1S. Clients decide which investment recommendations to accept and implement. Clients are also free to select any brokerage, insurance or other product provider to purchase (or sell) the investments, insurance, or other products discussed with C1S. C1S does not guarantee results, and losses can occur from receiving Consulting Services. Changes in client's financial condition, personal circumstances, goals, or general economic conditions may trigger changes to the advice provided by C1S. To the extent that material changes have occurred to a client's circumstances or goals, or to the extent a client requests C1S address a new project, the client will be asked to sign a new Services Agreement. All Consulting Services advice is based on information provided by the client. It is the client's responsibility to be certain that C1S has current and accurate information. Financial Planning Services C1S also stands ready to perform Financial Planning Services which are designed to combine advice relating to a range of financial subjects selected by the client. In designing a project or comprehensive financial plan, regardless of the complexity, Representatives will:  Interview the client, analyze the client’s financial needs, and assist the client in developing realistic goals and objectives based on information provided by the client. The Representative may also clarify planning problems and outline strategies designed to meet the client’s goals. A client typically retains C1S to perform a comprehensive plan covering such topics as investments, taxes, insurance, retirement, and estate planning, among other subjects. A client may also engage a C1S Representative for projects that may require annual or more frequent reviews if more complex long- term planning is needed.  Prepare an initial written project or comprehensive plan in the scope requested by a client based on the information gathered during the client interview and needs evaluation. This plan may include establishing a clear set of objectives, an outline of resources, a written investment policy statement, an asset allocation model, strategy recommendations, retirement, estate, education, or insurance planning and product recommendations. Reports usually include the steps to take for implementing advice provided.  Help the client implement the plan including, if needed, assistance in purchasing and/or selling securities and/or insurance products.  Review the plan periodically in the scope and frequency agreed upon in advance with the client. The Representative may also, as requested, recommend changes to the client’s investment portfolio or plan, either in writing or verbally. Changes in the client’s financial condition, personal circumstances, goals, or general economic conditions may trigger changes in the plan. To the extent material changes have occurred to a client’s circumstances or goals, or to the extent a client requests a new project, the client will be asked to sign a new Services Agreement. The client may initiate contact with the client’s Representative as often as needed and the Representative will schedule conferences as needed, usually no less than annually. Clients decide which investment recommendations to accept and implement. Clients are also free to select any brokerage, insurance or other product provider to purchase (or sell) the investments, insurance, or other products discussed with C1S. C1S is also a securities broker-dealer and many of its Representatives are also licensed to offer securities and insurance products. C1S and the Representatives will receive customary commissions for the sale of such products should a client decide to make purchases through C1S and a Representative. Clients are free to purchase such products other than through C1S and the Representative. This compensation creates a conflict of interest. All planning is based on information provided by the client. It is the client’s responsibility to be certain C1S has current and accurate information to enable C1S to prepare the initial plan, and it is the client’s responsibility to inform the Representative of material changes affecting the investments and planning strategies implemented so the Representative has them for future reference. If a conflict exists between the interests of C1S and the interests of the client, the client is under no obligation to act upon C1S' recommendations and if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through C1S. Retirement Plan Services C1S can provide the following services to retirement plan accounts:  ERISA Section 3(21) Plan Investment Advisory Services: C1S can perform non-discretionary investment advisory services at the retirement plan level as described below. (a) C1S will review and/or prepare the plan’s Investment Policy Statement ("IPS"), including assessing the following: (a) the criteria for selecting money managers and the due diligence procedures that the plan followed in selecting its money managers and/or mutual funds; (b) the basis for asset mix and rebalancing limits; (c) the performance measurement criteria; (d) monitoring procedures of money managers and other investment-related vendors; (e) composition and relevancy of quarterly performance reports; (f) composition of custodial reports; and (g) termination procedures for money managers. (b) C1S will advise client of appropriate investment categories for client’s retirement plan consistent with client’s adopted policy statement. (c) C1S will advise client of appropriate assets/investment instruments which are consistent with the investment categories selected by client. (d) C1S will monitor performance of the investment choices of client and provide periodic advice regarding possible changes to the investment selections. (e) Client shall have ultimate authority for selecting the investments for client's retirement plan.  ERISA Section 3(21) Participant Investment Advisory Services: C1S can perform non-discretionary investment advisory services for plan participants as described below: C1S will provide individual investment advice to client's Plan participants in the scope and at the times mutually agreed between client and C1S. Such advice may include specific recommendations; however, the Plan participants retain ultimate authority with respect to the investment of their Plan assets.  ERISA Section 3(38) Plan Investment Management Services: C1S can perform discretionary investment management services at the plan level as described below. Note, this service is distinct from the Section 3(21) services described above. (a) C1S will review and/or prepare the plan’s Investment Policy Statement ("IPS"), including assessing the following: (a) the criteria for selecting money managers and the due diligence procedures that the plan followed in selecting its money managers and/or mutual funds; (b) the basis for asset mix and rebalancing limits; (c) the performance measurement criteria; (d) monitoring procedures of money managers and other investment-related vendors; (e) composition and relevancy of quarterly performance reports; (f) composition of custodial reports; and (g) termination procedures for money managers; (b) For a participant-directed individual account plan, the IPS will set forth the number of general investment options and asset class categories to be offered to plan participants with a goal of providing a menu of investments that will allow for the creation of well diversified portfolios designed to provide for long-term appreciation and capital preservation through a mix of equity and fixed income exposures. (c) Once client approves the IPS, C1S will review the investment options available through the plan and will notify the plan’s record keeper as to C1S’s instructions to add, remove and/or replace specific “core” investment options to be offered to plan participants that meet the criteria set forth in the IPS. C1S will monitor the core investment options and, on a regular basis, provide reports to client and instructions to the plan’s record keeper to remove and/or replace investments that no longer meet the IPS criteria. C1S may, to the extent consistent with its fiduciary duties, select "core" investment options that provide revenue sharing; provided that, however, any compensation C1S may receive from revenue sharing payments shall offset its fees and any 12b-1 fees C1S may receive shall be rebated to the plan. (d) C1S will retain final decision-making authority with respect to removing and/or replacing investments in the core lineup, and the client will not have any further responsibility to communicate instructions to any third-party, including the plan’s record keeper, custodian and/or third-party administrator. (e) C1S will monitor investments in the plan’s accounts with Custodian and shall implement changes to investment selections as C1S deems appropriate.  ERISA Section 3(38) Participant Investment Management Services: C1S can perform discretionary investment management services for plan participants

as described below: (a) C1S will comply with the plan's written investment policy statement with respect to plan assets invested through participant's plan account. (b) C1S will provide a participant with investment advice, which may include asset allocation advice designed to identify one or more optimal retirement plan investment allocations, and may thereafter select investments for the participant's plan account pursuant to the discretionary authority granted to C1S by the participant in a separate discretionary account management agreement. (c) C1S will direct or effect transactions within the participant's plan account in securities and/or insurance products whose characteristics are deemed by C1S to correspond to participant’s investment objectives. (d) C1S will direct or make such periodic adjustments to participant's plan account as it deems necessary, in accordance with the participant’s financial circumstances, investment objectives and risk tolerance, as identified by the participant, and subject to the reasonable restrictions imposed by the participant. (e) C1S may hire and terminate third party investment managers (“Managers”) to manage all or a portion of the participant's plan account.  Non-Fiduciary Services: C1S can perform the non-fiduciary services as described below. (a) C1S will meet with representatives of client, at intervals mutually acceptable to client and C1S, to discuss investment performance. (b) C1S will provide client with a quarterly report regarding: (i) performance of each investment selected by client for client’s plan; and (ii) performance of one or more comparative benchmarks. (c) C1S will assist client with selection of any plan service providers as requested, but client shall be ultimately responsible for selecting other plan service providers. (d) C1S will contact client at least annually to determine if there have been any changes in client’s investment policy statement, and will remind client at least quarterly, in writing, that client should inform C1S if there have been (or are anticipated to be) any such changes. (e) As requested, C1S will conduct informational/educational group meetings with plan participants at initial installation of the plan, and periodically thereafter in the scope and frequency mutually agreed upon between client and C1S regarding: (i) general investment concepts; (ii) investment objectives and performance of selected investments; and (iii) investment allocations and strategies available to meet various investment objectives. C1S's assistance in participant investment education shall be consistent with and within the scope of the definition of investment education found in Department of Labor Interpretive Bulletin 96-1 unless C1S has agreed to provide individual investment advice concerning the prudence of any investment. Services Involving Recommendations to Other Investment Advisers for Mutual Fund and Variable Annuity Management Services C1S has entered into agreements with third party investment advisers specializing in mutual fund management. C1S refers clients to such third party advisers in return for a portion of the advisory fee paid by the client. Third party investment advisers include, but may not limited to: Constellation Wealth, Security Benefit, Nationwide Advisory, Freedom Advisors, Brookstone Capital AssetMark, Inc., SEI Investment Advisory Group, Lockwood Financial Group, , BTS Asset Management, Inc., CLS Investments, LLC, Orion Portfolio Solutions, Envestnet, , , and Howard Capital. The programs offered by these firms may not be available to all clients because of account minimums, client objectives and manager restrictions. For specific details regarding the above referenced firms, C1S recommends that clients review the individual firm's ADV Part 2A brochure delivered to the client prior to or at the time of opening an account. C1S's services include assisting a client in selecting a third party investment adviser whose investment styles and strategies suit the client’s individual needs and financial objectives. The investments managed in these accounts are usually limited to mutual funds and exchange-traded funds. With most programs, C1S's role is usually limited to making the referral. In others, C1S assists the client in completing an investment planning questionnaire to help guide the third party adviser’s investment decisions for the client. C1S may also assist clients in making investment and portfolio allocation decisions for these accounts. Depending on the program selected by the client, the third party adviser may or may not have discretionary power to purchase or sell investments in the client’s account. C1S Representatives are available to their clients to discuss the selected manager’s performance. Also, clients may or may not pay a sales load for mutual funds or annuities, or commissions on other investments placed within the client’s account. CreativeOne Wealth, LLC (f/k/a ChangePath LLC) Platform Services C1S has entered into a sub-advisory relationship with CreativeOne Wealth, LLC (f/k/a ChangePath, LLC) a registered investment adviser that is also an affiliated entity. CreativeOne Wealth, LLC provides a Platform service which allows C1S Representatives to have access to back office support which includes, but is not limited to, the ability to provide clients with consolidated reporting and other client relationship management tools. In addition, CreativeOne Wealth, LLC offers a discretionary management program that consists of proprietary models. A C1S representative assists the client in completing an on-line investment questionnaire which then creates an investment proposal ("Investment Proposal"). The Investment Proposal consists of model asset allocation recommendations based on the client's risk tolerance, time horizon, investment objectives and restrictions, tax status and financial sophistication. Each asset classes may include but not be limited to, stocks, exchange-traded funds ("ETFs"), mutual funds and external third- party money managers. The Investment Proposal may also recommend an Indexed Annuity product consistent with the client's investment objectives. Indexed Annuities are considered insurance products and are not sold through C1S, but as indicated below in Item 10 C1S Representatives may also be insurance licensed. These products are sold through Creative One Marketing which owns C1S, as noted above. The C1S Representative does not have discretion over the purchase or sale of the insurance product. It is at the client's sole discretion to determine whether to include the Indexed Annuity product from the Investment Proposal in their investment portfolio. The C1S Representative will only have discretionary trading authority over the assets included in the models. If the client chooses to include an Indexed Annuity product in their portfolio, the C1S Representative will receive a sales commission directly from the insurance carrier. The assets invested in the Indexed Annuity will not be included as assets under management when determining the advisory fee for the CreativeOne Wealth, LLC Platform service. The client's portfolio and its performance are monitored by the client's Representative. The frequency of these reviews and transactions made for a client's account are determined by the Representative. C1S Representatives typically meet with the client on an as-needed or as-requested basis to discuss the portfolio and other aspects of the service with a minimum of one annual review. Investments are not held by C1S. Instead, all investments managed by C1S through the CreativeOne Wealth, LLC Platform are held at the brokerage firm ("Custodian") through which transactions are placed. For this program the Custodian is Charles Schwab & Co., Inc. ("Schwab"). As noted above C1S Representatives will exercise discretionary authority granted by clients. When doing so, it allows Representatives to select the securities to buy and sell, the amount to buy and sell, when to buy and sell, without obtaining specific consent from the client for each trade. Clients should be aware that Representatives may make different recommendations and effect different trades with respect to the same securities and insurance products to different advisory clients. Rebalancing of the asset allocation models by CreativeOne Wealth, LLC will occur as necessary. Account rebalancing is accomplished by buying and selling shares of stocks, mutual funds or ETFs to reach target allocations, or moving funds between external third-party money managers to reach target allocations. Separately Managed Advisory Services C1S and its Representatives offer individual discretionary investment management services for their 401(k) or other employer sponsored qualified plans. Representatives will review the clients financial circumstances and objectives along with the investment offerings within the plan and allocate and rebalance the funds within the account to meet the clients investment goals. Clients typically grant C1S discretion to monitor and manage the account, which means they will have the authority to make rebalance the investments within the account without first obtaining permission from the client for each transaction. C1S will not have custody of the account, but C1S will be granted web based access to the account through the client's username and password information. This access will be limited to viewing the account and processing securities transactions only. Client Choice Investment Management Services C1S provides clients with investment management and reporting services by means of its Client Choice Investment Management service. Through the service, clients receive investment analyses, investment recommendations, statement reflecting holdings and transactions and on-going account monitoring services by a C1S Representative. C1S Representatives will be granted discretionary trading authority by the client. This allows C1S to buy and sell securities within the account at the times and prices that they feel is in the best interest of the client and in line with the client's investment objectives. Clients are free to impose reasonable restrictions on the types of investment in the account. The initial investment recommendations are based on financial information gathered from the client including net worth, risk tolerance, financial goals and objectives, client investment restrictions, and overall financial conditions. Investment in the Client Choice program are not held by C1S. Instead, all investment managed through this program are held by a qualified custodian, Charles Schwab & Co., Inc. ("Schwab"), a broker-dealer, member FINRA/SIPC. To the extent a client receives any account or other investment ownership statements from C1S. C1S recommends the client carefully compare the report to Schwab's statements. As of December 31, 2023, C1S has regulatory assets totaling $1,631,995,562 under discretionary management and $ 86,846,691 under non-discretionary management.